IR 05000397/1980004
| ML17275A630 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/02/1980 |
| From: | Bishop T, Haist D, Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17275A629 | List: |
| References | |
| 50-397-80-04, 50-397-80-4, NUDOCS 8010150031 | |
| Download: ML17275A630 (69) | |
Text
.
U. S.
NUCLEAR REGULATORY COMt1ISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
- Report No. 50-397/80-04 Docket Ho. 50-397 License No.
CPPR-93 Licensee:
Washington Public Power Supply System P. 0.
Box 968
'ichland, Washington 99352 Facility Name:
Washington Nuclear Project No.
(WNP-2)
Investigation at:
WNP-2 Site, Bento'n County, WA; Seattl Summary:
Investi ation conducted between November
1979 and Februar
1980 Re ort No.
0-39 8 -0 e,
WA and environs; Tigard, Oregon Investigation conducted:
November 27-30; December 5-7, 12-14, 1979; Jan.
9-11, 22-25, 29-Feb.
1, Feb.
11-14, 25-28, 1980.
Inspectors:
4/~ za
~r T.
W. Bishop actor Inspector Date Signe gyes z
D. P.
Hai t, Reactor Inspector Date Signe 4c ~.
le
<. J.
Wagn actor Inspector Date Signe
+asu Owen C. Shackleton Jr.,
In estigator D te igned Approved By:
Z.
8'o Rona C.
,
C ie, ProJects Section Date Signe Reactor Construction and Engineering Branch Areas Investi ated:
Non-routine, unannounced investigation by regional based inspectors an an investigator of reported photocopying of inspector s signatures on pipe whip inspection records and other record irregularities.
The investigation subsequently expanded to the sacrificial shield wall and included examinations of personnel qualifications, records and records generation practices, fabrication and inspection procedures, and completed work activities.
The investigation involved 294 hours0.0034 days <br />0.0817 hours <br />4.861111e-4 weeks <br />1.11867e-4 months <br /> by three NRC inspectors and an NRC investigator.
- Report Number correction April 9, 1980.
, 801(j X5g0$l
Report Summary Areas Ins ected:
Routine, unannounced inspection by regional based inspectors o
construction activities including:
safety related pipe welding, safety related pipe supports and restraints, licensee action on previously identified items, and investigation of allegations concerning pipe support design and contract 213A quality program.
The inspection involved 83 inspector -hours onsite by three NRC inspectors.
Results:
Of the eleven areas investigated and the three areas inspected, 20 items of noncompliance were identified.
2.
3.
5.
6.
7.
8.
9.
10.
12.
13.
14.
15.
16.
17.
18.
19.
20.
Violation - Shield wall not erected in accordance with design require-ments, paragraph 4.a.
Infraction - (Repeat item) - Failure to properly maintain safety related instrument tubing, paragraph 4.b.
Infraction - Failure to properly control weld fillermaterial, paragraph 4.e, 7.b.
Infraction - Failure to approve pipe whip restraint procedures prior to use, paragraph S.b.(1).
Infraction'
Failure to approve shield wall ultrasonic test procedure prior to use, paragraph 5.b.(1).
Infraction - No formal procedures were generated to control heat straight-ening of the sacrificial shield wall, paragraph 5.b.(1).
Infraction - No formal procedures were generated to control heat straight-ening of pipe whip restraints, paragraph 5.b.(1).
Infraction - Procedures for weld sequence and distortion control were not submitted to the engineer, paragraph 5.b.(l).
Infraction - Pipe whip restraint quality records do not accurately identify inspection personnel, paragraph 5.b. (4). (a).
Infraction - Shield i~all quality records do not accurately identify in-spection personnel, paragraph 5.b. (4).(a).
Infraction - Uncertified personnel performed NDE on pipe whip restraints, paragraph 5.b.(2).(c), 5.b.(2).(d).
Infraction - Uncertified personnel performed NDE on the shield wall, paragraph 5.b.(2).(c), 5.b.(2).(d).
Infraction - Failure to accomplish repairs to the shield wall in accord-ance with code requirements, paragraph 5.b.(4).(b).
Infraction - Failure to perform ultrasonic testing in accordance with procedure and code requirements, paragraph 5.b.(4).(c).
Infraction - Failure to properly install and inspect pipe support, para-graph 6.a.
Deficiency - Failure to properly document piping inspection, paragraph 6.b.
Infraction - Shield wall do not accurately reflect the activities per-formed, paragraph 5.b.(2).(b).
Infraction - Pipe whip restraint quality records contain inconsistencies and do not accurately reflect quality activities, paragraph 5.b.(2).(b).
Infraction - pipe whip restraint quality records do not correctly identify NDE inspector, paragraph 5.b.(2).(b).
Infraction - Pipe whip restraint quality record was signed and dated by an individual prior to his employment date, paragraph 5.b.(2).(b).
m l
DETAILS Persons Contacted for Shield Wall Pi e Restraint Investi ation Washin ton Pub ic Power Su
S stem WPPSS D. L. Renberger, Assistant Director for Technology W. C. Bibb, Project Manager H. E. Witherspoon, Quality Assurance Division Manager A. H. Sastry, Project Management Specialist J.
H. Steidl, WNP-2 Sr. Quality Assurance Engineer K. Cowan, Project Engineering Manager G. I. Wells, Construction Manager R. H. Foley, Project Management Specialist R. S. Sallee, Sr. Quality Assurance Engineer J.
Bean, Quality Assurance Engineer C. 0. Wright, Quality Assurance Engineer B. Boyum, Engineer Burns 8 Roe, Inc.
B8R)
R.
C. Root, Deputy Project Manager M. J. Parise, Special Projects Manager H. R. Tuthill, Assistant Project Quality Assurance Manager L. Good, Assistant Resident, Project Engineer J. McCormick, Manager, Corporate Quality Assurance P. Grable, Quality Assurance Engineer Leckenb Com an Ben E. Weeks, Chairman of the Board Alex E. Kunzler, President Philip D. Moore, Quality Assurance Manager Robert D. Pittsenbarger, Chief Engineer John A. Smistad, Production Manager F. Will Yogi, Project Manager In addition 6 welders/welding supervisors, ll current or former inspec-tion personnel and 7 other individuals were contacted.
II Management interviews were held with principal licensee representatives on November 28 and December 14, 1979, and January 30, February 26, and 28, 1980.
Management interviews were held at the Leckenby Company on November 30, 1979 and January 25, and February 14, 1980.
Mr. R. J.
Lewis of the Bonneville Power Administration attended the manage-ment meeting of February 26, 198.
Persons Contacted for Routine Ins ection
.a ~
Washin ton Public Power Sup l S stem WPPSS)
b.
C.
W. C. Bibb, Project Manager G. I. Wells, Deputy Project Manager Construction W. G. Conn, Startup Support Supervisor D. L. Renberger, Assistant Director, Technology R. T. Johnson, Project guality Assurance Manager J.
M. Steidl, Construction equality Manager D. C. Timmins, SSW Task Force Leader G.
K. Afflerbach, Deputy Project Manager, Startup R.
M. Foley, Deputy Project Manager A. M. Sastry, Project Management Specialist J.
A. Landon, Test Group Supervisor, Startup W. H. Smith, Assistant Construction Manager J: Zimmerschied, guality Assurance Engineer Burns and Roe B&R)
G. T. Harper, Jr., Technical Support Manager M. J. Parise, Contract 213A Director R.
D. Carmichael, Project guality Assurance Lead Surveillance H.
R. Tuthill, Assistant guality Assurance Manager Pittsbur h Des Moines PDM d.
H. Pannella, Project Manager T. Foley, Quality Assurance Manager (plus 5 other PDfl personnel)
WSH/Boecon/Bovee and Crail GERI WBG)
P. Sly, guality Assurance Manager L. Buckner, guality Control Supervisor W. Martin, Superintendent
- Welding A management interview was held with principal licensee and construction manager representatives on February 27, 1980.
3.
Construction Status As of January 25, 1980, the licensee considered construction of the WNP-2 project to be 81.4X complet.
Licensee Action on Previous Ins ection Items a
~
Open) ~liolation 50-397 79-12/04)
Gaps and Shims between Sacri-ficia Shie d Sections 3 and During an inspection of the sacrificial shield wall in June, 1979, the inspector identified shims between sacrificial shield wall rings three and four resulting in a through-shield gap of up to 4 inch in places.
The authorization and installation instructions for the shims or an analysis of the possible deleterious effect of the gap was not available at that time.
The licensee was requested to investigate this condition.
The NRC Region V received a
CFR 50.55(e) report on October 31, 1979 concerning plug welds between r ings three and four of the sacrificial shield wall.
This report stated that splice plates on the exterior surface and plug welds on the mating surface of rings three and four are designed to carry the radial and tangen-tial shear due to seismic loads, annulus pressurization due to pipe break, and pipe break reaction loads.
The plug welds are made through 96-1~ inch x 4 inch slotted holes in the bottom ring girder of the upper cylinder.
Due to mismatch between the mating surfaces,
-the shim plates mentioned above were inserted at the interface to level and align the segments of the upper cylinder prior to final welding.
Some of the shim plates were positioned under the slotted holes of the ring girder and subsequently, at those locations, the top girder (ring 4 and above)
was welded to the shim plates instead of to the matching ring girder below (ring 3).
The licensee's investigations indicated that this condition may exist for a majority of the 96 plug welds.
The licensee's evaluation of the safety implications of this de-ficiency was that in a design basis pipe break accident or seismic event, the'plug welds made to shim plates would not be capable of transferring shear loads between the upper and lower cylinders of the sacrificial shield.
The remaining plug welds and splice plates would be overstressed, resulting in potential structural failure affecting the capability of the sacrificial shield wall to perform its safety function The licensee stated in a description of the sacrificial sh'ield wall submitted to the NRC Directorate of Licensing on March 21, 1974 (letter No. GC2-"74-41) that shim plates and temporary members in the wall at jacking bearing points will have been removed prior to the commencement of plug welding and splice plate welding.
Burns and Roe Drawing No. 2808-5836, Rev. 2, Reactor Building Sacrificial hield Mall SH.9, Note NN also specifies removal of temporary shims before welding the inner and outer column splice plates and slot welding the bottom segment ring beam to the top of the box ring beam (top of ring 3 to bottom of ring 4).
Procedure No. 215-00-282, LEFP-1, Rev.
2 Fabrication and Erection Procedure for the Sacrificial Shield Mall Section III-B, Field Erection - Upper Portion, Page 17 specifies that temporary shim are to be removed prior to welding the splice plates and plug welds connecting the upper portion of the sacrificial shield wall to the lower portion.
The sacrificial shield wall fabrication and erection drawings and procedures do not address the use of permanent shims at the interface between rings 3 and 4.
Specification 2808-215 section 15A, Page 15A-133 only addresses the use of a suitable shielding material to fill any gap over 1/8-inch occurring during construction at the interface between rings 3 and 4.
The 215 mechanical contractor submitted a Request for Information - RFI No. 2571 on August 4, 1977 to obtain approval for Leckenby to use steel shims from 10GA to 3/16 inch to fill'he gaps and maintain the 1/8 inch gap tol-erance.
This request was approved by Burns and Roe on August 4,
1977 with the understanding that the shims be shown on the final issue of the as built drawings.
The final as-built.Leckenby Drawing No. F-124, Shim Layout at Ele-vation 541-5, was submitted by Leckenby on February 2, 1978 and approved by Burns and Roe on t1arch 26, 1978..
The drawing shows a continuous layer of shims of variable thick-ness (33-16 Ga.,
27-11 Ga., 14-3/16", 36-4").
The failure to join the upper and lower segments of the sacrificial shield wall in accordance with the drawings and erection proce-dures is a violation of 10 CFR 50, Appendix B, Criterion V which requires activities affecting quality to be accomplished in accord-ance with instructions, procedures or drawings and is considered to be an item of noncomplianc H
(0 en)
Noncom liance 50-397 79-16 06
Failure to ro erl ro-tect an maintain sa et re ate instrument rac s
an instrument tubin Contract 218 The licensee's response to the items of noncompliance was reported to NRC: RV in WPPSS's letter No. G02-80-30 of February 4, 1980.
The letter stated that all deficient equipment was cleaned and sealed or capped, that surveillances were increased and that a revised maintenance procedure was issued.
The revised maintenance pro-cedure was reportedly issued 'to clarify maintenance requirements and establish specific time intervals for maintenance performance.
The letter further stated that System Lineup Test I-3 was issued to control removal and installation of instruments under the jurisdiction of plant startup personnel.
The licensee reported that full compliance was achieved on January 31, 1980.
In examining the implementation of the cormitted actions, cognizant contractor (contract 218) representatives provided copies of sur-veillance reports which provided evidence that surveillance activ-ities had been increased.
The inspector also examined System Lineup Test I-3 which appears adequate to control system clean-liness during the removal and installation of instruments.
It was found, however, that revised maintenance procedure had not yet been approved and issued, as indicated by the WPPSS letter.
Li-censee representatives stated that the revised procedure had been developed but was held,up in the approval chain.
The represent-atives explained that it was anticipated that the procedure would be issued prior to January 31, 1980, and that it was an oversight that the letter to the NRC was not corrected to reflect the fact that the procedure had not actually been issued.
Subsequent to the inspection WPPSS provided a revised response to the Notice of Violation which correctly stated the status of the maintenance procedure.
This aspect of the corrective action will be examined during a future inspection.
The inspector examined 12 safety related instrument racks in the reactor building to assess the effectiveness of the actions taken.
The racks examined were Nos.
H22-P001, H22-P006, H22-P009, H22-P010, H22-P022, H22-P024, H22-P029, H22-P026A, H22-P004, H22-P027, H22-P005, and IR-66.
The examination revealed that instrument lines in two of the racks were open, exposing the system internals.
Rack No. H22-P005 had three sections of tubing which were disconnected and not capped.
Rack H22-P004 had one calibration port which was
-6-not capped.
Licensee representatives stated that the open tubing may be a result of work performed by another site contractor, (see item 4.c below). It is apparent, however, that the action taken to date has not been effective in assuring compliance with Fisch-bach/Lord procedure CP 208 which requires
"covers, caps, plugs, and other closures shall be maintained intact".
The failure to follow these procedural requirements is contrary to the requirements of 10 CFR 50, Appendix B, and is a repeat item of noncompliance.
(Open Noncom liance 50-397 79-16 08
Failure to com
with roce ur a re uirements for ca in or closin instrument i in an tubin contract The licensee's response to the item of noncompliance was reported to NRC: RV in HPPSS letter No. G02-80-30 of February 4, 1980.
The letter stated that:
deficient areas had been inspected for clean-liness and recapped; craft and gA personnel had been retrained on the subject of cleanliness control and that, surveillances had been doubled.
The inspector examined the contractor's (contract 220) records of training and recent surveillance reports which indicated the spec-ified actions had been taken.
Six safety related penetration assemblies were examined in the field and found to be properly controlled.
However, in examining the response to another item of noncompliance (see item 4.b above), it was found that three tubing sections had been disconnected and not capped on an instrument rack (No. H22-P005).
Licensee representatives stated that this disassembly had probably been accomplished by the 220 contractor when he last worked on this rack (approximately September 1979).
Accordingly, this item will remain open pending further licensee investigation into this matter and the response to the item of noncompliance identified in paragraph 4.b.
above.
(0 en)
Noncom liance 50-397 79-16 09
Safet related com onents sn t e reactor rotectson s stem were not s eclf)ed or Dure ased to E ectrical Safet Class IE and Seismic Cate or I re uirements.
The licensee response to the item of noncompliance was reported to NRC: RV in lrlPPSS letter G02-80-30 of February 4, 1980.
The letter stated that engineering directive No. 218-E-2340 was being processed to replace existing equipment with qualified, or type tested equipment.
It was also stated that the FSAR would be re-viewed to clarify requirements of the turbine generator inputs to the Reactor Protective System.
At the time of the current inspection it was found that the engineer-ing directive was in the review cycle and that the FSAR review was in progress.
This item will be further examined upon completion of these, and related, action (0 en) Unresolved Item (50-397/80-01 02) Held filler material ma not e contro e
sn accor ance wst roce ura re usrements Because of the identification of uncontrolled weld filler material during the NRC inspection of January 15-18, 1980 an examination of the prime mechanical contractors weld material control system was con-ducted during the current inspection.
The results of the examina-tion, provided in paragraph 7 of this report, indicate that weld filler material is not being properly controlled.
The status of this item is, therefore, changed from unresolved to an item of noncompliance, as identified in paragraph 7b.
(0 en) Followuo Item 50-397/79-14 Ol):
Contractor's documented 1ns ectors trainin ro ram does not insure continued com liance ws t A SI N..
contract A revision to the contractor's inspectors training and qualifica-tion procedure (gCP-22)
had been drafted, but the revision did not include provisions for assuring compliance with the intent of the ANSI standard in the area of prerequisite experience or education for inspection personnel.
This was reviewed with licen-see representatives who stated that action would be taken to assure the contractor's program is consistent with FSAR requirements in this area.
This item will be reexamined during a subsequent inspection.
(Closed)
Followu Item 50-397 79-14/04) Contract 215 review of subcontractor s activities The status of the contractor's review of his subcontractor's activ-ities were reviewed.
The contractor has initiated reviews of the shield wall subcontractor (see NRC report 50-397/79-16),
the Borg-Harner valve subcontract, and Metal Bellows subcontract.
The review is proceeding basically in accordance with procedure HP-154, which provides guidelines for controlling procurement and subcontracted services.
The completion of these reviews is considered a long term task by the contractor.
The results of the reviews will be periodically reexamined in conjunction with the routine inspec-tion program.
(0 en) Followu Item 50-397 79-16
Possible Pi e Hall Thinnin an Note f ect.
The question of possible wall thinning on large bore piping prepared for inservice inspection was closed in IE Inspection Report No. 50-397/
80-01 based upon ultrasonic wall thickness measurements taken by the licensee at the request of the inspector.
The licensee no-tified the inspectors of a possible wall thinning problem on small bore socket welded carbon steel piping.
Pipe fitters have been using a belt sander to clean coatings from the ends of the pipe to prepare it for socket welding.
The problem was discovered by a quality control inspector who noted a flat spot on the piping.
The licensee
has sampled 150 welds and found 8 percent rejectable due to encroach-ment on minimum wall.
The licensee has found no problems with stain-less steel piping.
The licensee is evaluating this problem for
CFR 50.55e applicability.
This item will be examined in sub-sequent inspections.
The licensee issued Corrective Action Request CAR-2808-215-1431 and received a reply from the contractor concerning possible notch effect at field welds joining components of different diam-eters.
The contractor has rejected the welds listed in the CAR and is retraining all first line and punch inspectoi s concerning the requirement for a 3:1 transition slope at these welds.
Work Procedure No. 140 will be revised to require slope transition to be verified by quality control final punch.
The licensee has not yet verified the corrective action promised and stated that the CAR will be returned to the contractor to require reinspection of systems that have already received final punch.
This item will remain open and will be examined during a subsequent inspection.
5.
Investi ation of Irre ularities Relatin to the Sacrificial Shield a
an Certain Ps e Hhl Restraints a 4 Back round and Summar of Investi ation Results On November 20, 1979, the Washington Public Power Supply System notified the NRC:RV of potential construction deficiencies in approximately 180 Class 1 pipe whip restraints to be used inside the containment on the main steam and feedwater systems.
The licensee's quality assurance record review identified discrepan-cies such as:
ultrasonic (UT) and magnetic particle (MT) test reports which do not reference the test procedures used; changes to welder identification numbers on UT and MT records without explanation; records of defects identified after painting with-out repair records"to document correction; and 50 or more UT/MT inspection records with the inspector's signature photocopied and the specific inspection data filled in with a felt-tipped pen.
The restraints were supplied by the Leckenby Company of Seattle, Washington and had been fabricated at their Seattle facilities.
Because of this condition a Stop Work Order was issued by the licensee on November 21, 1979, prohibiting further installation of pipe whip restraints.
A second Stop Work Order was also issued on November 21, 1979 to halt further work on the Sacrificial Shield Wall which was fabricated in Seattle and erected at the site by the same contractor and was the subject of a separate, on-going, HRC investigation (see NRC Report 50-397/79-16).
C
-9-The NRC:RV issued two immediate action letters to the licensee on November 21, 1979 confirming an understanding that installation of pipe whip restraints and work on the sacrificial shield wall would not proceed until the licensee's corrective action plan was examined by the NRC.
Based on the information that was available at the time, it was not clear whether the discrepant oipe whip restraint records represented a shortcut for reasons of expediency or an attempt at deliberate falsi-fication.
In view of the potential for falsification an investigation of this subject was initiated by NRC:RV on November 27, 1979.
From the results of the investigation it was concluded that some records were improperly filled out to cover the fact that some in-spections were performed by a non certified individual.
Sworn statements taken by the NRC from the individuals involved and com-pany management indicate the improper actions were accomplished without the knowledge of senior company officials.
In the course of the investigations several other concerns were identified.
These concerns indicate a breakdown in the quality program of not only the Seattle based fabricator, but also the audit and surveillance, systems of the site contraCtor, construction manager, and licensee who were responsible for monitoring the off-site activities of the fabricator.
A summary of the concerns are provided below:
(1)
Ultrasonic examination of the shield >>all was performed prior to approval of the UT procedure by the engineer (BAR) (50-397/80-04/01).
(2)
Pipe whip restraint nondestructive testing personnel quali-fication procedures and the ultrasonic examination procedure were not approved prior to the initiation of nondestructive testing (50-397/80-04/02).
(3)
The forming of curved plates for the sacrificial shield was accomplished without the benefit of approved procedures (50-397/80-04/03).
(4)
Heat straightening (the application of heat and mechanical force) was performed on shield wall and restraint components without the benefit of approved procedures or the generation of quality records (50-397/80-04/04, shield wall; 50-397/80-04/05, whip restraints).
(5)
The shield wall procedure for weld sequence and distortion control was not submitted to the engineer (BAR) for review and approval (50-397/80-04/06).
-10-(7)
(8)
(9)
Information on restraint and shield wall quality records was occassionally omitted.
Inspectors, at some later date, filled in the missing information with'out having direct knowledge of the activity which the record was to document.
Pecords do not accurately reflect the activities oerformed.
(50-397/
80-04/07, shield wall; 50-397/80-04/08, whip restraints).
Individuals who were never qualified by the contractor performed nondestructive examinations (NDE) on the sacrificial shield wall and pipe whip restraints.
In the case of the restraints, qualified inspectors names were applied to the NDE records so that the records would appear acceptable (50-397/80-04/09, whip restraints; 50-397/80-04/10 shield wall).
NDE personnel who were certified by the contractor were not qualified in full accordance with the requirements of SflT-TC-1A.
These individuals performed NDE on the shield wall and restraints (50-397/80-04/10, shiel d wal 1; 50-397/80-04/09, whip restraints).
Restraint bolting was not accomplished in accordance with AISC High Strength Bolting Specification, i.e. plate or bar wash-ers have not been used over long slotted holes (50-397/80-04/ll).
(10) guality records have not been maintained which document the qualification of some NOE examiners or identify the individ-uals who performed many of the visual inspections on the shield wall and whip restraints (50-397/80-04/08, whip restraints; 50-397/80-04/07, shield wall).
(11) Repairs to the sacrificial shield were not performed in accord-ance with the requirements of the Structural Welding Code AWS D.1.1 (50-397/80-04/12).
(12) Ultrasonic test records for whip restraints indicate that UT was not performed in accordance with the procedure or AWS Dl. 1 requirements (50-397/80-04/13)
.
The above concerns were identified to licensee representatives as the investigation progressed.
Licensee corrective actions for many, of these concerns have already been initiated, as identified in WPPSS letter No. 602-80-28 of February 1, 198 b.
Investi ation of Records Irre ularities The fabrication of pipe whip restraints was accomplished by the Leckenby Company, at Seattle, Washington, under llPPSS contract No. 2808-90.
As of November 1979 all the pipe whip restraints had been shipped to the !NP-2 site and 30 of the 179 restraints had been installed.
The Leckenby Company had also been contracted to fabricate and erect the sacrificial shield wall for 'HNP-2 under a subcontract to Bovee, Grail/GERI, the prime site mechanical con-tractor (contract No. 2808-215).
The sacrificial shield was fab-ricated in subassemblies at the contractors Seattle facilities, with final erection occurring at the site.
The sacrificial shield wall was completed in 1978, although attachments to the wall were still in progress in November 1979.
The investigation included:
an examination of selected procedures applied to the fabrication of the restraints and the shield wall; interviews with personnel involved in the fabrication, erection, quality inspection, surveillance, engineering, and management; observations of fabricated structures; and review of quality records.
The results of the investigation were as follows:
(1)
ualit Assurance Im lementin Procedures The following procedures associated with the fabricator and inspection of the sacrificial shield wall and pipe whip re-straints were examined:.
Procedure No.
Title LEFP-Rev.
OCP 5.0 Rev.
QCP 5.1 Rev.
QCP 8.0 Rev.
QCP 8.0 Rev.
QCP 8.2 Rev.
OCP 8.4, Rev.
Fabrication and Erection Procedure for the Sacrificial Shield i<all Quality Assurance Training and Qual-ification In-Process Inspection Nondestructive Testing Procedure for Ultrasonic Inspection (Pipe Hhip Restraints).
Ultrasonic Testing (Sacrificial Shield llal 1 )
Qualification and Certification Pro-cedure for Nondestructive Test Per-sonnel Nondestructive Test Qualification Criteria
-12-UT procedure gCP 8.0, Rev.
1 was approved by B/tR for exami-nation of sacrificial shield wall components on September 27, 1976 and the sampling program evaluation standards for lamellar tearing were later revised by BIER in revision NC approved by BAR on February 7, 1977.
Ultrasonic test reports indicate the following component examination dates:
~Com onent Ring beam 113b 113c 114c Date Examined Joints 23,
June 17, 1976 31,
23,
Box Column 29 b 29 a Held Haps M45 H21 H22 Joints 21-28 1-8 Joints 9, 10 1-6, 8-10 12,
1-4, 6-8, 10, 11, 12, 13, 167 June 16, 1976 July 24, 1976 Weld Map H22 15, 16, July 24, 1976 22, 132, 140 30, 168, 155, 32,
35, 37, 166 Electro-Slag joints X-100 X-102 These reports indicate that UT examinations were being performed on shield wall components prior to the approval of procedures by BSR.
The failure to provide approved procedures for the conduct of UT examinations is contrary to the requirements of 10 CFR 50, Appendix B, Criterion V.
This is an apparent item of noncomoliance (50-397/80-04/01).
0,
-13-UT procedure OCP 8.0 Rev.
0 was approved by B&R for examina-tion of whi p restraints on November 8, 1976.
Ultrasonic test reports indicate the following pipe whip restraint exar ination data:
Comoonent Date Examined PHS-30-5 PWS 27-17 PMS 6-1 September 27, 1976 and October 13, 1976 September 20, 1976 September 3, 1976 Procedure No.
OCP 8.2 Rev.
0 Oualification and Certification Procedure f'r Nondestructive Test Personnel and gCP 8.4, Rev.
0, Nondestructive Test gualification Criteria, were approved by Leckenby for use on the pipe whip restraint contract
on October 20, 1976 and was approved hy the architect-engi-neer on November 8, 1976.
As described above, ultrasonic ex-amination were performed on PMS 30-5, 27-17 and 6-1 in Sept-ember 1976.
The failure to provide approved nondestructive test orocedures prior to the start of work is contrary to the requirements of
CFR 50, Appendix B, Criterion V.
This is an apparent item of noncompliance.
(50-397/80-04/02).
Pipe.whip restraint contract HPPSS-90 requires nondestructive testing personnel qualification and certification in accordance with the edition of SNT-TC-1A in effect at the time of receipt of bid.
The contract was issued for bid on October 20, 1975 which would have designated June 1975 as the applicable edit-ion of SNT-TC-1A.
The licensee stated that Leckenby did not receive the June 75 edition of SNT-TC-1A until December 1975 and had already prepared their NDE qualification and certifi-cation program in accordance with the 1971 edition of SNT-TC-1A which was accepted by the architect-engineer.
The in-spector had no further questions in this area.
In addition to the above, the contractor and licensee were requested to provide procedures used to control: the forming of the curved plates used in the shield wall; heat straight-ening of each segment of ring beam 3 and segment 2A of ring beam 2 and other shield wall components as documented on Man-ufacturing Order Nos.
000904, 000913, 000916, 1193, 1666, and others; heat straightening of numerous whip restraint sub-
-14-assemblies, as documented on Manufacturing Order Nos. 0710, 0726, 0730, 0735 and 0736; and the shield wall weld sequence and distortion control program.
Regarding the requests for the above procedures it was found that no specific procedures had been generated for the cold forming of the curved plate sections.
Contractor and Licen-see representatives state that "standard industry practice" was used.
This item is unresolved pending identification of the specific method and controls applied to forming of the curved plates (50-397/80-04/03).
It was reported that no written procedures were generated to control the heat straighteninq of the shield. wall segments and whip restraint subassemblies despite the specific controls required by the Structural Helding Code AHS D.1.1.
The failure to generate procedures for the control of the above activities is contrary to the requirements of 10 CFR 50, Appendix B, Cri-terion V which requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings.
These are apparent items of noncompliance (50-397/80-04/04, shield wall; 50-397/80-04/05, ship restraints).
It was determined that the contractor had developed a document entitled "Sacrificial Shield Mall Assembly Procedure" which included information on weld sequence control.
The document did not contain a procedure or revision number nor an issue date.
It was also determined that this document had not been submitted to the engineer (Burns 5 Roe)
as required by the Structural Melding Code AHS D1.1, paragraph 3.4.3, which was invoked by the contract specification.
The failure to follow the procedural requirements of submitting the weld sequences to the engineer is contrary to the requirements of 10 CFR 50, Appendix B, Criterion V which requires activities to be per-formed in accordance with prescribed instructions.
This is an apparent item of noncompliance (50-397/80-04/06).
No other items of noncompliance or deviation were identified.
Interviews with Personnel Personnel involved in fabrication, inspection, surveillance, engineering, and management of the shield wall and whip restraints were interviewed.
This included welders, welding supervisors, current and former inspectors and insnection supervisors, a
former welding engineer, contractor quality assurance manager, former manufacturing superintendent, chief engineer, President, and Chairman of the Board.
Fifteen sworn statements were taken from the 30 individuals interviewed.
The interviews disclosed the following concerns:
-15-(a)
Heat straightening was accomplished on each of the three segments of shield wall ring beam 3 and segment 2A of ring beam 2 without the, benefit, of controlling procedures.
This condition was previously reported in paragraph 5.b.(1)
above.
(b)
Information on restraint and shield wall quality records was occassionally omitted.
Inspectors, at some later date filled in the missing'nformation without having direct knowledge of the activity which the record was to document.
The records do not accurately reflect the activities performed.
The above condition was stated by individuals interviewed and is supported by a large number of inconsistencies and irregularities found in the records themselves.
As examples, for the pipe whip restraints:
((1)) UT reports for restraints nos.
PWS 1-1 and 2-1 reported that the UT was performed on October 5, 1976 after post weld heat treatment (PMHT) where as the manufacturing orders for the same restraints recorded PINT as occur-ing on October 6, 1976; ((2)) The UT report for PWS 30-5 was dated October 5, 1976, was labeled "after stress relief" and had a photocopied inspector's signature whereas the stress relief chart for the load of components which contained this pipe whip restraint indicated the stress relief date as October 7, 1976; ((3)) Manufacturing Order No. 0750 for restraint No. PMS-53-14 indicates that inspector No.
5 performed HT on the restraint on September 24, 1976, whereas the HT report for that re-straint bears the photocopied signature of a different inspector; ((4)) Hagnetic particle inspection (HT) re-port for restraint PWS 36-9 reports that HT was performed on welds"6 and 7 on August 4, 1976 whereas the record bears the photocopied signature of an inspector who was not hired until August 16, 1976; ((5)) HT reports for PWS 36-23, 52-8, 36-1, 35-5B, 34-5B, 32-7 contains data
'and inspection results written by one inspector and bears the photocopied signature of a different inspector (the two individuals reported that they did not collaborate on the inspections involved); ((6)) Shield wall ultra-sonic test report for piece No. 113/78 is not dated and results of testing are not indicated; ((7)) Shield wall Hanufacturing Order No. 000917 indicates that welds 1-4 on drawing 75 were performed using welding procedure No. 0001-13-06 (the electroslag welding process);
the
-16-(c)
weld map for these welds indicates the welds were made using procedure No. 0001-01-10 (the shielded metal arc welding process);
((8))
Two shield wall weld maps Nos.
A383ER/029092 were used to make welds 4, 5, and 6; the second map indicates electrodes Nos.
A383ER/036084 were used to make the same welds.
Numerous weld maps showed evidence of changes in inspector, welder, welding procedure, and filler material identification numbers without explanation.
Based on the above it is not assured that the quality records accurately reflect the activities performed on the structures.
This is contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVII which requires sufficient quality records be maintained to furnish evidence of activities affecting quality.
These are apparent items of noncompliance (50-397/
80-04/16, shield wall; 50-397/80-04/17, 18, 19, pipe whip restraints).
Refer to paragraph 5.b. (4).(a) for additional examples of this noncompliance.
Individuals who were never qualified by the contractor performed nondestructive examination on the sacrificial shield and pipe whip restraints.
In the case of the re-straints, qualified inspectors names were applied to the NDE records so that the records would appear acceptable.
One individual provided a sworn statement indicating that he had performed magnetic particle testing (HT) on swing shift for approximately one year, but was never quali-fied by the contractor to do so.
It was reported that he would partially complete the HT records but would not sign them, since he had not been qualified and certified by the contractor.
An examination of selected records showed several instances where the unqualified individual had filled out the MT data, including results, and a qual-ified inspector's signature was applied to the record form to make it appear acceptable.
Examples are the HT reports for restraint nos.
PWS 27-1, 33-4, 32-3, 31-4, 28-1, 28-2, and 27-5.
The inspectors whose names appeared on the MT reports stated that they had not performed the designated magnetic particle testing.
The failure to correctly identify the inspector who performed the HT testing on the restraints is contrary to the requirement of 10 CFR 50 Appendix B, Criterion XVII.
This is an apparent item of noncompliance (50-397/80-04+9).
Examination of the sacrificial shield wall nondestructive
-17-examinations for similar discrepancies identified one individual who had performed ultrasonic examinations on plates Nos.
b56 and f56 and had not been qualified or certified by the contractor to perform ultrasonic examinations.
The failure to qualify individuals who per-form special processes, such as nondestructive examination on the shield wall and restraints is an apparent item of noncompliance (50-397/80-04/10).
Refer to paragraph 5.b.(2).(d)
for additional examples of this noncompliance.
(d)
Nondestructive examination personnel who were certified by the contractor were not qualified in full accordance with the requirements of SNT-TC-1A.
Three of the individuals interviewed reported that they had been certified to perform NDE by the contractor, but had not been qualified in strict accordance with the re-quirements of the American Society for Nondestructive Testing Reconmended Practice No. SNT-TC-1A, as required by the contract.
It was reported that in many cases the individuals had not been required to take the written
"specific" examinations or practical examinations required by SNT-TC-1A and that in some'ases individuals were given the answers to the written examination in advance of the tests for study purposes.
The practice of giving test questions in advance could not be substantiated by other than verbal statements.
An examination of inspector qual-ification records disclosed that:
((1))
The individual who performed the majority of the
'ltrasonic testing (UT) on the shield wall had not taken a practical examination which was in accord-
. ance with SHT-TC-lA.
He had performed a
UT as a part of his qualification, but the required 10 point
"practical". examination criteria for acceptance was not defined, nor was the "practical" qraded.
The following UT reports are examples for testing performed by this individual: ring beam 113b, welds 23/24 dated June 17, 1976; ring beam 1146, welds 15/16 dated June 17, 1976; subassembly 56b for segment 22A, welds 212 to 235 dated June 17, 1976.
The failure to properly qualify individuals performing special processes, is an apparent item of noncompliance (50-397/80-04/10).
-18-((2))
An individual had been certified to perform HT on the pipe whip restraints but had not taken a
required "specific" written examination specified by SNT-TC-lA.
This is an apparent item of noncom-pliance (50-397/80-04/09).
No other items of noncompliance or deviations were identified.
(3)
Observation of Fabricated Structures Selected welds on the completed shield wall and four pine whip restraints were examined for conformance to ANS O.l.l, design drawing, and FSAR requirements.
Previous shield wall inspec-tions had been performed by the NRC:RV (see inspection reports 50-397/79-12).
Licensee corrective action for determining the structural acceptability of the shield wall is currently in progress.
The inspectors verified that the stop work orders for the shield wall and pipe whip restraints were in effect.
During the investigation selected external shield wall welds at the 541 ft. elevation were examined.
Nine welds were ident-ified to licensee representatives as not conforming to the requirements of AHS Dl.l.
The whip restraint welds which were examined were found to be in accordance with the, visual acceptance criteria of AMS Ol.l and the design drawings.
It was found, however, that the bolt-ing of the assemblies for all whip restraints utilizing long slotted holes was not in full accordance with the 1972 version of the AISC Specification of Structural joints using ASTH A325 or A490 Bolts.
The bolting specification requires that structural plate or continuous bar type washers are used to cover long slots that are in the outer plies of joints.
llhile the contractual requirements for this bolting were not clear, licensee repre-sentatives stated that the bolting would be changed to comply with the requirements of the AISC specification.
This item will be further examined during a subsequent inspection (50-397/80-04/11).
Ho items of noncompliance or deviations were identifie (4)
Review of ualit Records The inspectors reviewed selected quality records associated with the fabrication, heat treatment and inspection of the sacrificial shield wall and pipe whip restraints.
This in-cluded an examination of weld maps, manufacturing orders, nondestructive examination records, selected material records, and inspector qualification records.
In addition to. those concerns identified previously, in para-graphs 4a, b, and c,.three additional concerns were ident-ified as follows:
(a)
guality.records which identify the individuals who performed many of the visual inspections on the shield wall and whip restraints and document NDE examiner qualification are not retrievable.
SiIjeld ygll m~gufacturing or(~rs for pieces a
, 15c, d
,
g
, t
,
15 V, and b
(no serial No. had been recorded on these manufacturing orders)
documented in-spections performed by inspector No.
7 between January 16, 1976 and March 1, 1976.
The contractor has no rec-ords available to provide the identity of this individual.
'he only records available are for an inspector No.
hired on December 3, 1976.
Similarly, Manufacturing Orders 000515, 000631, 1606, 1249, 1263, and 1569 doc-ument inspections by an inspector No.
4 in May and June 1976, whereas the only records available are for an inspector No. 4, an individual hired September 1, 1977.
Manufacturing Orders 2000, 2002, 2020, 1866, and 1945 document inspections by an inspector f(o.
6 in August 1976.
The only records available are for an inspector No.
hired on December 22, 1976.
For the pipe whip restraints Manufacturing Order No. 0457, for PWS-53-15, document inspections performed by an inspector No.
6 on August 13, 1976.
As stated no records are available for an inspector with this number at this time.
Manufacturing Orders 0213 and 0686, for restraints PWR 53-1 and 54-14 document inspections performed by an inspector No.
on July 21 and 22, 1976, whereas the only records available are for an inspector No.
9 hired on August 16, 1976.
The qualification records for inspector No. 9, who performed numerous UT and MT exams on the restraints could not be located (although statements of the gA Manager and a sur-veillance report indicated the individual had been certified; the qualification records for two restraint examiners, contracted
. from another organization, also could not be found, although pay records for these 'individuals showed that they had been promoted based on their NDE qualification.
The failure to maintain qualification records for inspection personnel
-20-and to identify the inspectors who performed the visual inspections documented on the aforementioned quality records or maintain records of qualification is contrary to the requirement of 10 CFP50, Appendix B, Criterion XVII.
This is an apparent item of noncompliance (50-397/80-04/08, pipe whip restraints; 50-397/80-04/07, shield wall ).
(b)
(c)
Repairs to the sacrificial shield wall were not per-formed in accordance with the requirements of the structural welding code AHS D.l.l.
An examination of the "Incomplete/Rejection Tags" for the shield walls identified thirteen cases where structural cracks were not repaired in strict accordance with the Structural Helding Code AHS D.1.1.
The code specifies that correction of cracks shall be accomplished by ascertaining the extent of the crack by the use of acid etching, magnetic particle inspec-tion or other positive means:
removing the crack and sound metal two inches beyond each end of the crack and rewelding.
Tag Nos.
5256, 5325, 5412, 6055, 6056, 6058, 6059, 5443, 5444, 5445, 5446, and 5447 identified cracks and specified the corrective meas-ures.
The measures did not include the use of acid etching, magnetic particle testing or other positive means to define the extent of the crack, nor did they specify the removal of two inches of sound metal beyond each end of the crack.
The repair techniques were discussed with cognizant personnel who stated that these code requirements were not always incor-porated in accomplishing crack repairs.
The indi-viduals stated magnetic particle or liquid penetrant testing was frequently used to check gouged areas, but was not always used.
It was further stated that the practice of removing 2 inches of sound metal beyond each end of the crack was not their standard practice.
The failure to perform repai rs in accordance with spec-ified procedures (the AHS D.l.l) is contrary to the requirements of 10 CFR 50 Appendix B Criterion V.
This is an apparent item of noncompliance (50-397/80-04/12).
Ultrasonic examinations of pipe whip restraints were not performed in accordance with the AHS code and the applicable examination procedure.
The structural welding code AHS D.1.1. requires a
straight beam examination of the entire base metal volume through which sound will pass prior to angle beam examinations to determine if there are laminar reflectors present which would interfere with the normal weld scanning procedure.
This requirement is incorpora-ted in the contractor's Procedure No.
gCP 8.0,paragraph Contrary to these requirements, UT test reports for PWS 315-5, 315-6, 315-7, and 315-8 as examples, show ~o evidence of straight beam examination prior to 70 angle beam examination.
The failure to meet the requirements of the ultrasonic examination procedure is contrary to the requirements of 10 CFR 50 Appendix B, Criterion V which requires that activities affecting quality be accomplished in accordance with procedures.
II This is an apparent item of noncompliance (50-397/80-04/13).
6.
Safety Related Pi e SuDoort and Restraint Systems WBG)
Observation of Work and Work Activities The inspector examined the following dynamic pipe supports for shaft travel smoothness and activation:
tlechanical Snubber No.
RHR 448 RWCU-128 RCIC-22 RCIC-38 HPCS-5 RHR-67 RFH-126 HS-135 Hodel No./Load ratin PSA-1/2 PSA-1/2 PSA-1 PSA-1 PSA-3 PSA-3 PSA-10 PSA-10
-22-All snubbers examined performed smoothly and locked upon activation.
No items of noncompliance or deviations were identified.
The inspector visually inspected the following fixed pipe supports for conformance to as-built drawings, contractor quality assur-ance procedures and Als attached with relatively light U-bolts.
As an example one support is made from 3/8" x 4" angle iron, bolted to the wall with
'four 7/8" x 5" anchor bolts, yet the pipe is attached with 1/4" U-bolts (infering that the 1/4". U-bolts are substantially weaker than the rest of the structure).
~pindin
The allegation was correct, but does not represent a safety concern.
While licensee representatives were unable to identify the current use of 1/4" U-bolts in pipe supports, it was found that some 1/4" U-bolts had been installed in the past and that this condition was subjected to engineering review and properly dispositioned.
The Burns
Roe program for reviewing the designs of completed pipe support assem-blies provides for an analysis to verify the as-built condition of the support thus providing reasonable assurance that the support will per-form its intended functio The results of the investigation of both topics were reviewed with the alleger on, February 27, 1980.
The alleger stated that he had never had a real concern for safety, but he was concerned with wastefully excessive pipe support structure designs and redundant inspections of anchor bolts.
The alleger had no further questions regarding the ability of the anchor bolts or supports to perform their safety function.
No items of noncompliance or deviations were identified.
Alle ations of De radation in Contract 213 ualit Pro ram On February 7, 1980 an NRC Inspector received six allegations concerning the quality program of the 213 contractor.
The allegations were inves-tigated by: examining the pertinent bolting procedure (No. PP-16713-22, revision C, entitled "Controlled Release Fastener Installation Procedure for Reactor Building"); interviews with four QC inspectors and discuss-ions with six other craft/QC personnel; observations of work activities (bolting of blow away panels at and above the 606 ft. elevation of the reactor building); and examination of quality records (selected Corrective Action Required forms, nonconformance reports, engineering corrective action requests, installation drawings, and QA surveillance records).
The alleger was contacted by the regional inspector, at which time the alleger explained that in the case of each of his allegations, he was aware that the defective hardware had been corrected.
He expressed his prime concern to be that of lack of action to preclude recurrence of such conditions.
II At the time of the investigation actions had recently been taken by the licensee to upgrade the quality of the contractor's activities.
These actions were taken in response to WPPSS findings of a lack of compliance to drawing, procedure, and QA Manual requirements, and included:
reinstruct-ion of all personnel-on contract, code, and QA requirements; implemen-tation of effective trend analysis; increased auditing; and assignment of a new contractor QA manager.
In addition, HPPSS assigned a Senior Quality Engineer to work with the contractor until quality concerns are resolved.
The allegations and results of the investigation were as follows.
a.
Allegation:
No disciplinary action was taken against craftsmen who removed bolt identification numbers and were preparing to renumber them to replace lost bolt Finding:
The allegation was not substantiated.
While the reported situation did occur, a Corrective Action Required form was issued to assure the proper bolting was installed and the subject of how to handle instances of missing material was reviewed with respon-sible personnel.
Allegation:
Iron workers are not following procedure sequence in installing quick release bolts.
Finding:
The allegation was not substantiated.
Discussion with cognizant personnel failed to substantiate this as a problem.
Sequence controls were established to insure components did not move from position when replacing standard bolts with quick release bolts.
Positioning has not been a recurring problem with the bolt replacement work.
Allegation:
Ironworkers are reaming holes to sizes larger than allowed, and installing bolts in the holes before gC can inspect the hole size.
Finding:
The allegation was not substantiated.
Bolt fit-up receives 100Ã inspection, which would identify oversized bolt holes.
'i<hile oversized holes are occasionally identified, in each case the con-dition is documented and a
new hole, of the proper size is drilled.
Allegation:
Some gC inspectors were told to sign off on a fit-up inspection which they had not inspected.
Finding:
The allegation was not substantiated.
No cases could be identified where gC had been directed to sign off for an inspec-tion that was not performed.
One case was reported where a ther-mocouple clip was installed without a fitup inspection.
This par-ticular case was reviewed by management with cognizant personnel.
Allegation:
gC inspectors have been threatened by ironworkers.
No disciplinary action was taken.
Finding:
The allegation was not substantiated.
While one confron-tation between iron workers and a
gC inspector was identified, this situation was addressed to the crafts by contractor manage-ment.
None of.the gC inspectors interviewed reported any instance of this nature except in the single previously mentioned instance.
Allegation:
gC inspectors are transferred from a job just as they get oriented and start to identify problem Finding:
The allegation was not substantiated.
Interviews with inspectors established that they are generally assigned to the areas where they are most experienced.
Some transfers are accomplished as workloads shift or to provide temporary inspection coverage, but no more than what would usually be expected.
During the course of the investigation it was found that several instances have been identified where radial downcomer bracing was found to have surface discontinuities throughout the length of the brace (NCR No.
06137).
The disposition of these braces has not yet been fully addressed by HPPSS.
It was of concern that the discontinuities may extend into the weld thus violating code requirements for preparation of weld edge bevels.
This item is unresolved and will be examined further during a subsequent inspection (50-397/80-02/16).
Subsequent to the investigation, the findings were reviewed with the alleger.
The alleger stated that he had no further questions regarding the reported conditions.
No items of noncompliance or deviations were identified.
10.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations.
Two unresolved items were identified during this inspection and are discussed in Paragraphs 5.b.(1)
and 9.f.
11.
Mana ement Interviews The inspectors and investigator met'ith licensee and Burns 5 Roe rep-resentatives on the dates listed in paragraph 1 and 2, and summarized the scope and findings. of the investigation and inspection.
Licensee representatives were responsive and have initiated corrective actions as documented in l<PPSS letter No. G02-80-28 of February 1, 198 I i
,
!
~PQ REMI
Op
C O
r Op o~
++*++
I UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION V
1990 N. CALIFORNIABOULEVARD SUITE 202, WALNUTCREEK PLAZA WALNUTCREEK, CALIFORNIA94596 FFB 89 russo p3 80048 00 Q'Ip Docket No. 50-397 Washington Public Power Supply System P.
0.
Box 968 Richland, Washington 99352 Attention:
Mr. N. 0. Strand Managing Director Gentlemen:
Subject:
NRC Inspection of WNP Unit 2 This refers to the inspection conducted by Messrs.
D.
P. Haist and J.
0. Elin of this office on January 15-18, 1980 of activities authorized by NRC Construction Permit No.
CPPR-93, and to the discussion of our findings held by Messrs Haist and Elin with Mr.
W.
C. Bibb and other members of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of pr'ocedures and representative records, interviews with personnel, and observations by the inspectors.
The inspection identified one continuing item of noncompliance concerning the adequate closure of instrument sensing lines.
This item was initially identified in NRC Inspection Report 50-397/79-16.
Response to the original item of noncompliance was provided in your letter of February 4, 1980.
The corrective actions identified in your letter will be examined during a future inspection.
No additional response regarding this item is required at this time.
In accordance with Section 2.790 of the NRC's "Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document, Room.
If this report contains any information that you believe
. Washington Public Power Supply System Qi to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure.
The application must include a full statement of the reasons why it is claimed that the information is proprietary.
The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be glad to discuss them with you.
Sincerely,
Enclosure:
A.
IE Inspection Report No. 50-397/80-01
~Jr+~-
G.
S. Spencer, Chief Reactor Construction and Engineering Support Branch
REGION V==
Report No.
50-397/80-01 Docket No.
50-397 License No.
CPPR-93 Safeguards Group Licensee:
Washington PUblic Power Supply System P. 0.
Box 968 Richland, Washington 99352 Inspection at WNP-2 Site, Benton County, Washington Inspection conducted:
January 15-18, 1980 D.
P. Haist, Reac r Inspector
. 0.
E in, eactor nspec or
=
Inspectors:
Faci1 ity Name Washington Nuclear Project No.
(WNP-2)
z xzlso Date Signed Date Signed Date Signed proved By:
S ucmiary:
R. T.
Dod
, Chief, Reactor Engineering Support Section Date Signed Inspection on Januar 15-18, 1980 Re ort No. 50-397 80-01 Areas Ins ected:
Routine, unannounced 'inspection by regional based inspectors o
construction activities including:
review of the licensee's responses to IE Bulletin 79-14; preservice inspection activities; safety related piping installation; electrical power, instrument and control cable pulling and termination; and licensee action on previous inspection findings.
The inspection involved 50 inspector-hours onsite by two NRC inspectors.
Results:
Of the five areas inspected, one continuing item of noncompliance
~dna equate closure of instrument sensing lines (paragraph 3.c of Details)
and one unresolved item was identified concerning failure to properly control welding filler material (Paragraph 8.0 of Details}.
RV Form 219 (2)
DETAILS 1.
Persons Contacted a.
Washin ton Public Power Su
S stem WPPSS
W.
C. Bibb, Project Manager
G. I. Wells, Construction Manager
R. Johnson, Project guality Assurance Manager
J.
M. Steidl, Construction guality Manager
A.
M. Sastry, Project Management Specialist
J.
D. Martin, Plant Manager, WNP-2
A.
N. Kagler, Design Supervisor
W.
H. Smith, General Superintendent
K.
D.
Cowan, Project Engineering Manager
G.
K. Afflerbach, Deputy Project Manager, Startup D. Welch, ISI Field Coordinator T. Hozle, Engineer J.
Zimmerschied, guality Assurance Engineer B.
Boyum, Engineer b.
Burns and Roe, Inc.
(B&R)
R.
C. Root, Deputy Project Manager
M. J.
Parise',
Special Projects Manager
G. T. Harper, Jr. Technical Support Manager
H.
R. Tuthill, Assistant guality Assurance Manager
R.
D. Carmichael, guality Assurance Engineer M. A. Lacey, Resident Project Engineer D. Graziano, Lead Manager Engineer J.
Snyder, Sr. Engineer, Design Supervisor Mechanical G. Englert, Group Supervisor, Mechanical M. Berestein, Resident Project Engineer c.
Lambert-Mac ill-Thomas LMT Inc.
M. King. Foreman E.
Wood, Level III Examiner In addition, Level I and Level II nondestructive examination personnel were interviewed.
d.
WSH/Boecon/Bovee and Crai 1/GERI WBG L. Buckner, guality Control Supervisor J. Wilkinson, General Superintendent B. Martin, Superintendent-Welding e.
General Electric IPSE F.
Paseka
- gC Supervisor
- Denotes those present at exit interview on January 18, 198 l
~
,
2.
Construction Status On January 18, 1980 the licensee considered the construction of the HNP-2 project to be 80.5 percent complete.
3.
Site Tour Immediately upon arrival at the site, the inspectors toured the containment drywell area to verify that the licensee's stop work order on the sacrificial shield wall and installation of pipe whip restraints was in effect.
No work in these areas was observed.
Following the entrance interview the inspector conducted a detailed site tour to observe the control of work activities and to examine the general state of housekeeping.
The following conditions were observed:
a.
Access control in the area of the control rod drive modules has been discontinued.
Extensive work activities in this area have resulted in dirt and debris including nuts, bolts, and structural steel shapes in and around the control rod drive modules.
b.
The standby liquid control storage tank discharge nozzle was open; the end protection on standby liquid control valve Y-1B was removed, exposing the valve internals; an adjacent stainless steel standby liquid control valve and four one-foot lengths of stainless steel piping were stored without dunnage on the floor; cable 1H7B-0403-C-DIY
was not properly supported as it exited a conduit and it's end was not taped or otherwise protected.
C.
The reactor vessel, level instrument B22-N026A on instrument rack H22-P004 was
'removed without capping or otherwise protecting the exposed instrument sensing lines on the instrument rack.
This was cited previously as an item of noncompliance (IE Inspection Report 50-397/79-16).
The inspector determined that startup personnel had removed the instrument for calibration and had not provided closure of the sensing lines while the instrument was removed.
This failure to follow site procedures for protection of exposed instrument sensing lines is a continuing, item of noncompliance.
The licensee produced documents showing that the housekeeping problem around the control rod drive modules had been identified by the HPPSS construction quality group on January 14, 1980.
General Electric had been directed to correct the situation.
The inspector reexamined the area on January 17, 1980 noting some improvement but structural steel debris remained in and around the modules, and the open ends of lines for control rod modules 138 and 141 immediately outside the containment wall were uncapped.
The licensee coomitted to correct these conditions and increase surveillance in this area.
The licensee also committed to correct the conditions around the standby liquid control syste U
-3-Licensee Action on Previous Ins ection Findin s
Closed)
Followu Item 50-397/79-14/02 Meld Re ect Rate.
The inspector reviewed the 215 contractor's program in the area of weld rejections.
When last examined, weld reject rates had been reduced from over 33% to between 15'A and 20K.
A superintendent remains assigned to weld quality and weekly status reports are still being issued.
The superintendent indicated that weld reject rates are currently between 6X and 17/ on new work.
The inspector reviewed status reports for the last six weeks and verified and stated progress in reducing weld reject rates.
This item is considered closed.
0 en)
Noncom liance (50-397/79-04/ll Batter Rack Installation The licensee is evaluating the battery with respect to possible replacement with a new Exide model requiring a different mounting
'rack str ucture.
There are numerous outstanding NCR's on the battery such as low specific gravities, overtorquing of intercell connections, and improper installation of supporting racks (Ref.
IE Inspection Report 79-09).
Additionally this model Exide battery is no longer available from the manufacturer.
The cells of the new Exide design will not fit on the racks presently installed.
The licensee intends to make a discharge capacity test of the battery and review the status of outstanding NCR's by March/April 1980 and determine then if replacement is necessary.
This item remains open pending pr oper installation of replacement of the battery.
0 en Followu Item 50-397 79-16/05
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Possible Pi e Wall Thinnin and Notch Ef ect.
Visual inspections of weld joints disclosed obvious reductions in pipe outside diameter at welds which had been prepared for inservice inspection.
The licensee took wall thickness measurements in response to the inspector's concern on the inlet side of valve RRC-V-60B and the lower side of valve RHR-V-14B.
Piping connecting to RRC-V-60B is specified as 24-inch diameter with a minimum wall thickness of 1.14 in~hes.
The minimum wall thickness was located at approximately 135 and was 1.21 inches.
Piping connected to RHR-V-14B is 18-inch diameter with a standard wall thickness of 0.375 inches.
The minimum wall thickness was 0.710 inches.
The inspector had no further questions on possible wall thinning.
Visual inspection of a pipe weldment-to-valve for the lower weld on valve RHR-V-14B had disclosed a sharp transition creating a possible stress riser.
Visual examination of other pipe to fitting weldments during this inspection disclosed similar condi tions at valves RHR-V-3A and RHR-V-68A and also at Class 3 main steam relief valve discharge piping to elbow welds h1S-547-3 field weld 3 and NS-547-2
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field weld 1.
Field weld number 3 had been visually inspected and accepted on July 31, 1978 and liquid penetrant accepted on August 2, 1978.
Field weld number I had been visually inspected and accepted on July 31, 1978 and liquid penetrant accepted on August 2, 1978, however a subsequent reinspection program on January 9,
1979 resulted in a surface defect rework record calling for a dditional filter material to eliminate the crevice.
The 215 contractor examined field weld number 3 and felt that the notch condition was probably acceptable although it was the same condition existing on field weld number l.
The licensee is issuing a corrective action request (CAR) to the 215 contractor outlining these conditions and requesting a program of corrective action.
Work Procedure 57, revision 9, attachment number 1 specifies, in part, that for transition contours where piping butt joints involve different outside diameters..."the groove shall be filled to the full depth of the joint prep on the thicker section."
The 215 contract gC inspectors have been inconsistent in interpreting the above requirements.
This item will remain open pending review of the 215 contractor's response to the licensee's CAR.
IE Bulletins IE Bulletin 79-14 - Seismic Anal sis for As-Built Safet -Related NRC Region V received a response to IE Bulletin 79-14 on September ll, 1979.
The response described, in general terms, the program utilized to ensure that the seismic analysis input information conforms to the as-built configuration of the plant, and indicated conformance with the intent of the"bulletin.
The licensee did not attempt the inspections required by the bulletin since the plant is under construction and at that time no safety-related systems had been completed and turned over to the licensee.
The inspector discussed the procedures used to insure that the elements required for seismic analysis are incorporated in the as-built drawings to the required accuracy.
The inspector reviewed the licensee's as-built policy directions to BER and Project Engineering Directive PED-215-1823 which revised the 215 contract specification to reflect additional as-built drawing requirements.
The inspector reviewed the 215 Contractor's Project Directive Numbers PD-82, Rev. 0, "As-Built of Large and Small Base Piping Isometrics" and PD 75 Rev. 4, "Hanger Engineering Standards",
and found that not all specification requirements are reflected in these procedures.
BKR and MPPSS representatives stated that they have audited approximately 60 out of 180 hanger as-builts and have
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found numerous problems.
Typical problems include deficiencies or discrepancies in the bill of materials, discrepancies in member sizes, incorrect clearances, and hanger locations out of tolerance.
B&R is now tabulating the problem areas and will resolve them with the 215 contractor.
As a result, BKR has not accepted any as-built drawings.
Licensee representatives feel that the problems will be resolved within 90 days.
The 215 and 216 contractor's procedures will be examined and NRC audits of as-built drawings will be performed during a subsequent inspection.
(50-397/80-01/01).
Review of 10 CFR Part 21 Submission b
General Electric Com an Concernin Oe ective Pin Cream s
sn Pane H 2-P853 Insert 72C at Sus uehanna.
An inspection of panel mounted connectors at WPPSS Unit 2 was made by General Electric Company in October, 1979.
A total of 107 connectors were examined of which one failed the pull test.
Three pins in termination module TM-46, termination cabinet P679 failed.
A visual examination indicated that the conductors had not been fully inserted into the barrel of the failed pins.
This termination was replaced.
The action taken was found to provide adequate assurance the connections will perform their intended function.
The inspector has no further questions at this time.
Preservice Ins ection Observation of Work and Work Activities The inspectors observed ultrasonic and liquid penetrant examination of the following pipe welds:
S stem and Weld No.
18 RHR-4-AL RHR Loop-A test line 4 RCIC-13-10 4 RCIC-13-11 RCIC steam supply Examination Liquid penetrant (PT)
Ultrasonic (UT)
Calibration and examinations were performed by certified examiners in accordance with procedures UTP-10 (Ultrasonic)
and PTP-1 (Liquid penetrant).
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The inspector examined calibration block numbers UT-l, UT-14, UT-16 and UT-17 against the as-built drawings.
The inspector found that the drawing for block UT-1 indicated a nominal wall thickness of 1.250 inches but the block was stamped with a wall thickness of 1.125 inches.
The drawing reflected the actual nominal thickness.
The licensee indicated that the block will be restamped.
The licensee immediately examined all blocks against the as-built drawings finding minor discrepancies in the stamping and missing material grade on one block.
The licensee stated that these discrepancies will be corrected immediately.
Nominal wall thicknesses are stamped on the blocks for information.
The range is determined from an IIW or rompas block prior to actual calibration on the blocks.
For this reason, the inspector had no further concerns in this area.
The inspector examined the material certifications for ultrasonic calibration block numbers UT-1 and UT-2 and found the certifications in accordance with the as-built drawings and stamping on the blocks.
Straight beam examinations were performed prior to fabrication-to ensure the absence of laminations.
No items of noncompliance or deviations were identified.
8.
Control of Weldin Filler Material During the observation of preservice examination activities at containment elevation 540, the inspector identified several pieces-of welding electrode which were not properly controlled.
- During observation of control rod drive insert and withdrawal line installation activities at containment elevation 560, the inspector further identified six unused type 7018 coated electrodes.
In both cases, the controlling NF-69 filler metal withdrawal forms, and portable rod ovens were not in the vicinity of the rod and the rod had not been bent to signify its rejection.
These findings were identified to the licensee and are unresolved pending a review of the contractor's overall weld material control system.
(50-397/80-01/02)
9.
Electrical Cables and Terminations a ~
Observation of Work and Work Activities.
The in process and completed work associated with 15 safety class 1E Power and control cables were observed.
The installation of these cables was examined for compliance with construction procedure CP404 "cable pulling and inspection" and NRC requirements for safety class lE cable placement.
The completed work associated with two 4160 volt power cables was also examined.
No deviations or items of noncompliance were identifie !'
b.
Review of ualit Records.
The audits of contractor 218 (Fishbach/Lord)
performed by the licensee in October 1978 and t1ay 1979 were reviewed.
Several items of finding noted in the Hay 1979 audit had been closed by the licensee with minimal explanation of why the item was closed.
Investigation into several of these findings revealed more justification for closing the item than had been documented.
The licensee stated that he would review these findings to insure complete documentation of the audit followup.
The inspector examined 18 site quality assurance surveillance reports pertaining to some cable pulling activities performed=
during the preceding twelve months.
The records were complete and indicated either satisfactory completion of safety related activities or unsatisfactory conditions were discussed and NCR documentation numbers noted.
No deviations or items of noncompliance were identified.
10.
Exit Interview An exit interview was conducted on January 18, 1980 and was attended by the representatives denoted in Paragraph 1.
The activities covered during the inspection and observation and findings of the inspectors were discussed.
The licensee committed to initiate a memorandum to GE and to increase surveillance of control rod drive piping to ensure that piping ends remain capped and free from contaminatio,I-t a 4
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